Dear Jaime Hoyle,

My name is Kimberly Rahimian and I am currently a graduate student at Virginia Commonwealth University in the Occupational Therapy Doctorate program. I am writing to request that the Board of Counseling reconsider the supervision requirements proposed in the Emergency Regulations for occupational therapists seeking registration as a Qualified Mental Health Provider (QMHP).

The profession of occupational therapy has strong foundational roots in recognizing the importance of meaningful activities (occupations) to promote mental health. In order to become an occupational therapist, individuals must graduate from an accredited occupational therapy program at the master’s or doctorate level, undergo rigorous fieldwork training for 24 weeks full-time, and pass the National Board Certification in Occupational Therapy (NBCOT) exam. Additionally, occupational therapy is recognized federally as part of recovery-oriented, quality mental health services and professions. Occupational therapists are highly trained health care professionals, who are qualified to play a vital role in addressing several different aspects of mental health, including evaluation, developing a plan of care, and intervention.   

Occupational therapists should not have to undergo additional burdensome requirements to become a QMHP. I am asking that the Part II Requirements for Registration regulation 18VAC115-80-40 B.5. Requirements for registration as a QMHP-A and 18VAC115-80-50 B.4. Requirements for registration as a QMHP-C be changed from the current Emergency Regulations to the following replacement:

Licensure as an occupational therapist by the Board of Medicine (§ 54.1-2900 of the Code of Virginia) with a master’s or doctoral degree, and an internship or practicum of at least 500 hours with persons with mental illness or one year of experience in a mental health setting.

Sincerely,

Kimberly M. Rahimian, OTS